February 12, 2016 The Honorable Al Franken United States Senate 309 Hart Senate Office Building Washington, DC 20510 Dear Senator Franken: Thank you for your letter of January 13, 2016, concerning Google Apps for Education and Chromebooks. We have always been firmly committed to keeping student data private and secure. We appreciate the opportunity to explain our products and the steps Google takes to protect our users’ information. Ensuring educators and students can learn and work together fits naturally with Google’s mission to organize the world’s information and make it universally accessible and useful. Google believes that technology levels the playing field and enables anyone to learn, anywhere. That’s why we build easy-to-use solutions that give teachers and administrators more time to educate and students more time to learn. One example is Google Apps for Education (GAFE), a free and secure set of productivity tools. Schools set up and make available to students the GAFE core services, such as Gmail, Google Calendar, Groups, and Drive, which includes Docs (word processing), Sheets (spreadsheets) and Slides (presentations). With GAFE, students can collaborate on projects in real-time from across the room or across the world. They can find and interact with the information they need, become creators and more engaged and active learners — and, ultimately, become better prepared for twenty-first century careers. For teachers, distributing and collecting homework and providing students one-on-one feedback become easier and more effective. GAFE services may be used on any device with a modern web browser. Many schools choose to use Chromebooks, which are affordable and durable laptops that can be used to access GAFE services and the rest of the Internet, under the schools’ management. Chromebooks, like, GAFE, have world-class security, which is critical to ensuring privacy of students’ personal data. Another example is Chrome Sync, a feature popular with both Chromebooks and the Chrome browser that enables Google Account holders to log into any Chromebook or Chrome browser
and find all their apps, extensions, bookmarks, and frequently visited sites. Each community and school district is different. Technology like Chrome Sync gives schools the flexibility they need to develop a system that works best for their community, whether this means one device per student or shared devices across classes. For students, this means that they can get to work, right away — even when a school doesn’t provide a device for each student, Chrome Sync makes a Chromebook instantly feel like the student's own. Digital literacy is an important component of ensuring the privacy and security of students’ personal information. So we work with experts to develop programs — such as the Online Safety Roadshow — that teach students what they can do to stay safe and secure online. Below are responses to your specific questions.
1. When a student is signed in to their GAFE account but is not using one of the GAFE services, what kind of data does Google collect on an individual student?
School administrators determine which services students can access and use. The GAFE core services are Calendar, Classroom, Contacts, Drive, Docs, Gmail, Forms, Groups, Sheets, Sites, Slides, Talk/Hangouts and Vault. Administrators control access to these GAFE core services as well as services outside of the GAFE core services. Schools may permit students to access additional Google services (like YouTube, Maps, and others) beyond the GAFE core services if they obtain the consent of a parent for minor students, and if the use is for educational purposes. Before we address those additional Google services, we would like to explain Google’s practices with respect to the GAFE core services. In GAFE, Google collects both personal data, like a student’s name and email address, as well as other information about how the services are used, such as the type of device and the IP address of the user’s network. How Google collects and uses information with GAFE accounts is described in the Google Apps for Education Privacy Notice. Google’s use of information in GAFE core services is limited by the Google Apps for Education agreement and the Data Processing Amendment (which schools
can accept in the GAFE Admin console). Google uses students’ personal data in GAFE core services only to provide these services, so students can do things like communicate using email and collaborate on assignments using Google Docs. There are no ads in GAFE core services, and student data in these services is not used for advertising purposes. If a school permits access to one of Google’s additional services outside the GAFE core services, such as Google Maps, Google collects the information described in our Privacy Policy. The information we collect in these services is similar to that collected from any other Google user, and includes: ● Information the user gives us, including personal information like name, email address, or telephone number. 2
● Device information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). ● Log information, including user entries like maps queries, the network’s IP address, and device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of the request and referral URL. If any of this data is associated with a student’s GAFE account — which may happen when a student is logged into their GAFE account — we consider it to be the student’s personal information. As we promise in the GAFE Privacy Notice, no K-12 student personal information is used to target ads, and in some services we show no ads at all. In Google Search, for example, we show no ads when K-12 students are logged in to their GAFE accounts. As described in more detail in response to question two, below, users who have Chrome Sync enabled (whether on a Chromebook or using the Chrome browser) will have additional information about their browser settings stored in their GAFE Account, including browsing history, any saved apps, extensions, bookmarks, and passwords. In addition, Chromebooks collect anonymous usage statistics and crash reports about users’ interactions with Chrome features. These statistics and crash reports are collected anonymously, meaning that we do not associate them with your Google Account when we collect them.
2. When a student is using a Chromebook but is not using one of the GAFE services, what kind of data does Google collect on an individual student?
There is very little difference between the data collected from a student using Google services on a Chromebook versus using a Google service on any other device, which we describe above. By default, Chromebooks anonymously collect usage statistics and crash reports, which involve information about the usage of Chrome features. Other than that, the fact that you are accessing a Google service, such as Gmail or Google Search, with a Chromebook does not cause Google to receive any additional or different information about you. Note that school administrators may restrict the websites and services accessible via the Chromebook, whereas other devices may not be so limited. Users who have Chrome Sync enabled (whether on a Chromebook or using the Chrome browser) will have additional information about their browser settings stored in their Google Account, including browsing history, any saved apps, extensions, bookmarks, and passwords. See our Help Center to learn more about Chrome Sync. If any of this data is associated with a student’s GAFE account — which is the case when a student is logged into a Chromebook with Chrome Sync enabled with their GAFE account — we consider this data to be the student’s personal information and do not use it to target ads.
3. If Google does collect any individualized data on a student, such as browsing information or viewing habits, when a student is using a Chromebook or is logged
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